Xerox Environment, Health and Safety Supplier Requirements: Chemical Bans/Restrictions and Part Marking

EHS 1001

Version 5.0 May 18, 2009

EHS 1001 Xerox EH&S Supplier Requirements: Chemical Bans/Restrictions and Part Marking v. 5.0 Page 1

Prepared by: Xerox Corporation Environment, Health and Safety 800 Phillips Road, Bldg. 0205-99F Webster, New York 14580 USA ©2009 by Xerox Corporation. All rights reserved. XEROX® and all Xerox product names mentioned in this publication are trademarks of XEROX CORPORATION.

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Table of Contents

1 Introduction...... 4 1.1 Objective ...... 4 1.2 Applicability ...... 4 1.3 Responsibilities of Xerox Suppliers 1.4 Future Updates...... 4 1.5 Questions/Additional Information...... 4 2 Specifications...... 5 2.1 Regulatory Compliance...... 5 2.2 Ozone Depleting Substances ...... 5 2.3 Chemical Substance Bans and Restrictions ...... 5 2.4 Parts Marking ...... 5 2.5 Packaging……………………………………………………………………………………………………..5

Appendix A...... 6 Xerox Specifications for Control of Chemical Substances in Products, Parts, Materials and Packaging

A.1 Objective ...... 6 A.2 Definitions...... 6 A.3 Specifications...... 7 A.3.i Prohibited Substances ...... 7 A.3.ii Xerox and REACH "Reportable" Substances ...... 14 Appendix B...... 16 Xerox Environment, Health and Safety Policy

Appendix C – see separate excel file Compliance Forms – Form EHS-1001A Xerox Supplier Certification of Compliance for Prohibited or Banned Substances Form EHS-1001B Xerox Supplier Report of “Reportable” Substance Use Form EHS-1001C Xerox Supplier Certification of REACH Reportable Substances

Appendix D ...... 17 Revision History

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1 Introduction 1.1 Objective This document establishes Xerox Corporation's environmental, health and safety (EH&S) requirements for its suppliers with regard to regulatory compliance, chemical bans and restrictions, and parts marking. The requirements support Xerox’s commitment to regulatory compliance, safe products, protection of the environment/human health and customer satisfaction as stated in the company’s corporate EH&S policy (Appendix B).

1.2 Applicability Xerox Corporation’s suppliers of products, materials, parts and packaging.

1.3 Responsibilities of Xerox Suppliers Xerox suppliers: - shall meet all requirements of this standard - shall certify compliance with this specification using all forms in Appendix C - shall retain information and/or data to demonstrate compliance with this specification including but not limited to the Xerox or supplier part number, part or material description, substance or substances disclosed, substance percentage used by weight, supplier certificates of compliance of components and materials, results of analysis and analytical source where applicable, and the name of a responsible person - shall provide, upon request, Xerox and/or third parties responsible for verification with copies of the aforementioned information as well as any other applicable compliance documentation - shall have an Environmental Management System

1.4 Future Updates Xerox will review this document on a periodic basis and will make any necessary revisions to ensure that these requirements remain relevant to current EH&S regulations, stakeholder requirements and industry practices. The changes are explained in Appendix D. Forms completed using earlier versions of this document remain valid unless new data is specifically requested.

1.5 Questions/Additional Information Please direct any questions about these requirements to your Xerox procurement contact.

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2 Specification

2.1 Regulatory Compliance Suppliers shall comply with all applicable EH&S laws and regulations in the jurisdictions in which they operate and shall comply with all EH&S laws and regulations applicable to the product, part, material, packaging or commodity provided to Xerox.

2.2 Ozone Depleting Substances Supplier shall not incorporate an Ozone Depleting Substance (ODS) as defined by the Montreal Protocol and the US Environmental Protection Agency Clean Air Act Amendments of 1990 in the manufacture or processing of a product, part, or commodity provided to Xerox. A list of ODS’ is available at http://www.epa.gov/ozone/ods.html.

2.3 Chemical Substance Bans and Restrictions Supplier shall meet the Xerox Specifications for Control of Chemical Substances in Products, Parts, Materials and Packaging as specified in Appendix A. Supplier shall provide the weight (in grams) of each battery contained in any given part or product. 2.4 Parts Marking Supplier shall mark plastic parts, assemblies and end-items provided to Xerox, with the resin content identification code as specified in Xerox Multinational Design Standard 88P215 “Methods and Requirements for Part Marking Identification” or ISO Standard 11469, “Plastics – Generic identification and marking of plastic parts”. Note that this requirement applies to parts weighing more than 24 grams. 2.5 Packaging

• Supplier must comply with the requirements as defined in Xerox Standard EH&S-710, “EH&S Requirements for Packaging” http://www.xerox.com/downloads/usa/en/f/FILE_EHSA_XRX_INFO_REQUIREMENTS_710.pdf • This standard specifies the minimum environment, health, and safety requirements for packaging of products, parts, or materials shipped to any manufacturing site, distribution center or customer from suppliers or other Xerox locations.

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Appendix A

Xerox Specifications for Control of Chemical Substances in Products, Parts, Materials and Packaging

A.1 OBJECTIVE This appendix details Xerox Corporation's specifications for prohibiting and restricting certain chemical substances in products, parts, materials and packaging provided to Xerox for use in Xerox products. Additional requirements apply to Xerox consumables.

A.2 DEFINITIONS Accessories: items not integral to, but necessary for, use of a product. Accessories include, but are not limited to, items such as power cords, finishers, feeders or product manuals. Batteries: any source of electrical energy generated by direct conversion of electrical energy, and consisting of one or more primary battery cells (non-rechargeable) or of one or more secondary battery cells (rechargeable). Consumables: items such as inks, toners, fuser lubricant or papers. Electronic product: electrical and electronic equipment that is within the scope of the waste electrical and electronic equipment Directive 2002/96/EC and/or the restriction of the use of certain hazardous substances in electrical and electronic equipment Directive 2002/95/EC. Engineered Nanomaterials: Engineered nanomaterials are those which have been manufactured to have at least one dimension between approximately 1 and 100 nanometers (nm); including but not limited to nanoparticles, nanofibers, nanopowders, nanotubes and nanowires, generically referred to as nano-objects, as well as aggregates and agglomerates of these materials. This includes a wide range of surface chemistries and applications. Impurity: residual quantities of chemical substances that are unintentionally present in raw materials or are by-products of the manufacturing process. Ingredient: any chemical substance intentionally used in the formulation of a material for use in the manufacture of electrical and electronic products or components thereof. Material: any chemical substance or homogeneous mixture of substances. New product: any piece of equipment put on the market for the first time, regardless of the date of launch of the particular model, and supplied as new. Packaging: refers to containment for the purposes of marketing, protection or handling of a product and shall include a unit package, an intermediate package and a shipping container. Part: any functional unit comprised of one or more mechanical or electrical components. Put on the market: the initial action by which a product is made available for the first time, i.e. leaves the factory or enters distribution, in the applicable territory. Re-used product: any piece of equipment that has already been placed for the first time on the applicable market and is then supplied as used or previously owned, without modification other than repair, reconditioning or upgrade. Spare parts: any part made available for replacement of like parts in existing equipment.

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A.3 SPECIFICATIONS A.3.i Prohibited Substances

The substances listed in Tables A1 and A2 shall not be used as ingredients in any material or part provided to Xerox for use in equipment, or in spare parts for use in products, or in accessories, or in packaging except as defined by further qualification or exemptions. Additional requirements apply to Xerox consumables as outlined in EH&S 701 Xerox Environment, Health and Safety Requirements for Materials.

RoHS1 Prohibited Substances:

Table A1 covers European Union RoHS prohibited or banned substances. These requirements apply to electronic products put into distribution for the first time after July 1, 2006 and/or parts and materials intended for use in electronic products put into distribution for the first time after July 1, 2006. Xerox only allows the use of these prohibited materials for applications that have been determined by the European Union to be exempt because substitutes are technically infeasible at this time or because substitutes would have adverse safety or environmental effects.

A list of approved RoHS exemptions may be found in Table A3.

Table A1. RoHS Prohibited Substances Substance Qualification Cadmium and its Prohibited unless its application is exempted per ROHS1. The substances shall compounds not be present in concentrations exceeding 0.01% by weight per homogeneous material used in parts or products2 . Hexavalent Chromium Prohibited unless its application is exempted per ROHS1. The substances shall and its compounds not be present in concentrations exceeding 0.1% by weight per homogeneous material used in parts or products2. Lead and its compounds Prohibited unless its application is exempted per ROHS1. The substances shall not be present in concentrations exceeding 0.1% by weight per homogeneous material used in parts or products2. Mercury and its Prohibited unless its application is exempted per ROHS1. The substances shall compounds not be present in concentrations exceeding 0.1% by weight per homogeneous material used in parts or products2. Polybrominated The substances shall not be present in concentrations exceeding 0.1% by weight per biphenyls (PBBs) homogeneous material used in parts or products2.

Polybrominated The substances shall not be present in concentrations exceeding 0.1% by weight per diphenylether (PBDEs) homogeneous material used in parts or products2. including deca-BDE

1 EU Directive 2002/95/EC on the restrictions of the use of hazardous substances in electrical and electronic equipment (RoHS) 2 EU Decision 2005/618/EC establishing the maximum concentration values for ROHS. Homogeneous material means a material that can not be mechanically disjointed into different materials. The term “homogeneous” means “of uniform composition throughout”, for example individual types of plastics, ceramics, glass, metals, alloys, paper, board, resins, plating, coating and finishes. The term “mechanically disjointed” means that the materials can be, in principle, separated by mechanical actions such as for example: unscrewing, cutting, crushing, grinding and abrasive processes.

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Table A2. Other Prohibited Substances in Xerox products, parts, materials, accessories and packaging

Applies to any material or part provided to Xerox for use in equipment, or in spare parts for use in products, or in accessories, or in packaging

Substance Qualification Reference Asbestos and asbestos Shall not be an ingredient. 76/769/EEC*, Marketing and Use materials of Dangerous Substances and amendments: (83/478/EEC; 85/610/EEC; 87/217/EEC; 91/659/EEC; 99/77/EEC). United States: Toxic Substances Control Act (restricts new uses); Azo Colorants Shall not be an ingredient if chemical breakdown results in release of 76/769/EEC, Marketing and Use aromatic amines listed in Directive 2002/61/EC. of Dangerous Substances and amendments: (2002/61/EC; 2003/03/EEC).: http://europa.eu.int/eurlex/pri/en/ oj/dat/2002/l_243/l_2432002091 1en00150018.pdf; Blue Angel Eco-Logo Benzene Shall not be an ingredient, or present as an impurity in 76/769/EEC, Marketing and Use concentrations ≥0.1% by weight. of Dangerous Substances, Blue Angel Eco-Logo Cadmium and its compounds In non-electronic products and accessories: banned from use as 76/769/EEC, Marketing and Use pigment, dye, or stabilizer in concentrations greater than 0.01% by of Dangerous Substances and weight . amendments: (91/338/EEC, 2006/66/EC, 93/86/EEC); 2002/95/EC (EU/RoHS Directive In packaging: the sum of the concentration levels of incidentally and its amendments) ; China introduced lead, cadmium, mercury and hexavalent chromium must Management Measures on EIP be less than 100 parts per million. Pollution Control; EU Battery Directive 2006/66/EC; EU In batteries: banned in concentrations ≥0.002% by weight Packaging & Packaging Waste Directive 94/62/EC Article 11

Formaldehyde Shall not exceed specified emission limits for composite wood California Code of Regulations products. Wood packaging materials, including pallets, are exempt Sections 93120-93120.12, Title from these requirements. See Table A2.1 for specific emission limits. 17. Hexachlorobenzene Shall not be an ingredient. Xerox Requirement Canada - Prohibition of Certain Toxic Substances Regulations, 2005. Hexavalent Chromium and its In packaging: the sum of the concentration levels of incidentally 2002/95/EC (EU RoHS Directive compounds introduced lead, cadmium, mercury and hexavalent chromium must and its amendments); China be less than 100 parts per million. Management Measures on EIP Pollution Control; EU Packaging & Packaging Waste Directive 94/62/EC Article 11 Inorganic Cyanide Compounds Shall not be an ingredient. See Table A2.2 for a specific list of Xerox Requirement compounds.

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Substance Qualification Reference Lead and its compounds Banned from use in paints or as a stabilizer in concentrations greater 76/769/EEC, Marketing and Use than 0.01% by weight. of Dangerous Substances and amendments: (86/677/EEC, In packaging: the sum of the concentration levels of incidentally 2006/66/EC, 93/86/EEC); introduced lead, cadmium, mercury and hexavalent chromium must 2000/53/EC 2002/95/EC be less than 100 parts per million. (EU/RoHS Directive and its amendments), China Management Measures on EIP In batteries: requires marking with the chemical symbol if Pollution Control; EU Battery concentrations ≥0.004% by weight. Directive 2006/66/EC; EU Packaging & Packaging Waste Directive 94/62/EC Article 11 Mercury and its compounds In packaging: the sum of the concentration levels of incidentally 76/769/EEC, Marketing and Use introduced lead, cadmium, mercury and hexavalent chromium must of Dangerous Substances and be less than 100 parts per million. amendments: (86/677/EEC, 2006/66/EC, 98/101/EEC; In batteries: banned in concentrations ≥0.0005% by weight 2002/95/EC (EU/RoHS Directive and its amendments); EU Battery In button batteries: banned in concentrations >2% by weight Directive 2006/66/EC; EU Packaging & Packaging Waste Directive 94/62/EC Article 11

Ozone Depleting Substances Shall not be ingredients. List of ODS’ available at (ODS) http://www.epa.gov/ozone/ods.ht

ml Pentacholorophenol Shall not be an ingredient. 76/769/EEC, Marketing and Use of Dangerous Substances with Prohibited in the treatment of wood. amendment,1999/51/EC Perfluorooctane sulfonate Shall not be an intentionally added ingredient in preparations in 76/769/EEC, Marketing and Use (PFOS) concentrations of ≥ 0.005% by weight. of Dangerous Substances and amendment 2006/122/EC: Shall not be an intentionally added ingredient in semi-finished http://eur- products or articles, or parts at concentrations ≥ 0.1% by weight lex.europa.eu/LexUriServ/LexUriSe calculated with reference to the mass of structurally or rv.do?uri=OJ:L:2006:372:0032:003 microstructally distinct parts. 4:EN:PDF

Phenol,2-(2H-benzotriazol-2-yl)- Japanese law concerning the 4,6-bis (1,1-dimethylethyl)- Shall not be an ingredient. evaluation of chemical substances (CAS# 3846-71-7) Polychlorinated Biphenyls Shall not be ingredients. The Law concerning the (PCBs) Examination and Regulation of Manufacture etc. of Chemical Substances (Class 1 chemical substances: Japanese law), 76/769/EEC, Marketing and Use of Dangerous Substances with amendment 85/478/EEC Polychlorinated Napthalenes Shall not be ingredients. The Law concerning the (more than three chlorine Examination and Regulation of atoms) Manufacture etc. of Chemical Substances (Class 1 chemical substances: Japanese law). Polychlorinated terphenyl Shall not be ingredients. The Law concerning the (PCTs) Examination and Regulation of Manufacture etc. of Chemical Substances (Class 1 chemical substances: Japanese law), 76/769/EEC, Marketing and Use of Dangerous Substances with amendment 85/478/EEC.

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Substance Qualification Reference Halogen-Containing Polymers Shall not be used for plastic packaging (includes PVC) Xerox Requirement ; Blue Angel Eco-Logo Radioactive Substances Shall not be ingredients. U.S. Nuclear Regulatory Commission Title10 CFR Part 20 (Annex C). Laws for the Regulation of Nuclear Source Material, Nuclear Fuel Material, and Reactors, 1986 (Japanese law) Short Chain Chlorinated Shall not be ingredients. EU Marketing and Use Directive Paraffins (76/769/EEC +2002/45/EC) 1,1,2-Trichloroethane Shall not be an ingredient. Xerox Requirement Tributyl Tin (TBT), Triphenyl Tin Shall not be ingredients. The Law concerning the (TPT), and Tributyl Tin Oxide Examination and Regulation of (TBTO) Manufacture etc. of Chemical Substances (Class 2 chemical substances: Japanese law) Class 1 chemical substances Japanese law for TBTO) Amendment to EU Directive 76/769/EEC, effective 2012

Table A2.1 – State of California Phase 1 and Phase 2 Formaldehyde Emission Standards for Hardwood Plywood (HWPW), Particleboard (PB), and Medium Density Fiberboard (MDF) – Phase 1 (P1) and Phase 2 (P2) Emission Standards (ppm) Effective Date HWPW-VC HWPW-CC PB MDF Thin MDF 1-1-2009 P1: 0.08 ------P1: 0.18 P1: 0.21 P1: 0.21 7-1-2009 ------P1: 0.08 ------1-1-2010 P2: 0.05 ------1-1-2011 ------P2: 0.09 P2: 0.11 ------1-1-2012 ------P2: 0.13 7-1-2012 ------P2: 0.05 ------Based on primary test method [ASTM E 1333-96(2002) in parts per million (ppm) Note: HWPW-VC=veneer core; HWPW-CC=composite core

* Note: Effective June 1, 2009 substances regulated under EU 76/769/EEC will be incorporated into Annex XVII of EU REACH 1907/2006.

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Table A2.2 – Inorganic Cyanide Compounds

No. Chemical Name CAS Number Formula 1 Hydrogen cyanide 74-90-8 HCN 2 Sodium cyanide 143-33-9 NaCN 3 Potassium cyanide 151-50-8 KCN 4 Silver cyanide 506-64-9 AgCN 5 Cyanogen bromide 506-68-3 BrCN 6 Barium cyanide 542-62-1 Ba(CN) 2 7 Copper cyanide 544-92-3 CuCN 8 Nickel cyanide 557-19-7 Ni(CN) 2 9 Zinc cyanide 557-21-1 Zn(CN) 2 10 Barium tetracyanoplatinate 562-81-2 BaPt(CN) 4 11 Dipotassium tetracyanomercurate 591-89-9 K Hg(CN) 2 4 12 Calcium cyanide 592-01-8 Ca(CN) 2 13 Mercury dicyanide 592-04-1 Hg(CN) 2 14 Lead dicyanide 592-05-2 Pb(CN) 2 15 Copper cyanide 4367-08-2 Cu(CN) 2 16 Potassium dicyanocuprate 13682-73-0 CuK(CN) 2 17 Potassium cobaltic cyanide 13963-58-1 K Co(CN) 3 6 18 Potassium dicyanoaurate 13967-50-5 KAu(CN) 2 19 Sodium copper cyanide 14264-31-4 Na Cu(CN) 2 3 20 Copper dicyanide 14763-77-0 Cu(CN) 2 21 Potassium nickel cyanide 39049-81-5 K Ni(CN) 2 3

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TABLE A3. ROHS Exemptions3

Substance Applications that are exempted Mercury, Lead, ƒ Spare parts for use in electronic products first put on the EU marketplace before 1 July 2006. Hexavalent Chromium, ƒ Parts for upgrading the functionality or extending the capacity of electronic products first put on the EU Cadmium, PBDEs, PBBs marketplace before 1 July 2006. ƒ Re-used electrical and electronic products first put on the EU marketplace before 1 July 2006. Mercury ƒ Mercury in compact fluorescent lamps not exceeding 5 mg per lamp. [1] ƒ Mercury in straight fluorescent lamps for general purposes not exceeding: o Halophospate 10 mg [2.1] o Triphosphate with normal lifetime 5 mg [2.2] o Triphosphate with long lifetime 8 mg [2.3] ƒ Mercury in straight fluorescent lamps for special purposes. [3] ƒ Mercury in other lamps not specifically mentioned above. [4] Lead • Lead in glass of (a) cathode ray tubes, (b) electronic components, (c) fluorescent tubes. [5] • Lead as an alloying element in steel containing up to 0.35% lead by weight, aluminum containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight. [6]

• Lead:

o in high melting point type solder (i.e. tin-lead solder alloys containing 85% by weight or more of lead). [7.1] o in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunication. [7.2] o in electronic ceramic parts (e.g. piezoelectronic devices). [7.3] • Lead in lead-bronze bearing shells and bushes [9b] • Lead in compliant pin connector systems. [11] • Lead as a coating material for the thermal conduction module C-ring. [12] • Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80% and less than 85% by weight. [14]

• Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit Flip Chip packages. [15] • Lead in linear incandescent lamps with silicate coated tubes. [16] • Lead halide as radiant agent in High Intensity Discharge (HID) lamps used for professional reprography applications. [17] • Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb) as well as when used as speciality lamps for diazo-printing reprography, lithography, insect traps, photochemical and curing processes containing phosphors such as SMS ((Sr,Ba)2MgSi2O7:Pb). [18] • Lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact Energy Saving Lamps (ESL). [19]

3 These exemptions are consistent with the EU Directive 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). The numbers in square brackets correspond to the listings in the Annex to the Directive. When further decisions on these exemptions are forthcoming, this standard may be updated.

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Substance Applications that are exempted Lead (cont…) • Lead Oxide in glass used for bonding front and rear substrates of flat fluorescent lamps used for Liquid Crystal Displays [LCD). [20] • Lead as impurity in RIG (rare earth iron garnet) Faraday rotators used for fibre optic communications systems. [22] • Lead in finishes of fine pitch components other than connectors with a pitch of 0.65mm or less with NiFe lead frames and lead in finishes of fine pitch components other than connectors with a pitch of 0.65mm or less with copper lead-frames. [23] • Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors. [24] • Lead oxide in plasma display panels (PDP) and surface conduction electron emitter displays (SED) used in structural elements; notably in the front and rear glass dielectric layer, the bus electrode, the black stripe, the address electrode, the barrier ribs, the seal frit and frit ring as well as in print pastes. [25] • Lead oxide in the glass envelope of Black Light Blue (BLB) lamps. [26] • Lead alloys as solder for transducers used in high-powered (designated to operate for several hours at acoustic power levels of 125 dB SPL and above) loudspeakers. [27] ƒ Lead bound in crystal glass as defined in Annex 1 (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC. [29] Cadmium ƒ Cadmium and its compounds in electrical contacts and cadmium plating4 except for applications banned under Directive 91/338/EEC amending Directive 76/769/EEC relating to restrictions on the marketing and use of certain dangerous substances and preparations. [8] Hexavalent chromium ƒ Hexavalent chromium as an anti-corrosion of the carbon steel cooling system in absorption refrigerators. [9] ƒ Lead and Cadmium ƒ Lead and cadmium in optical and filter glass. [13] ƒ Lead and cadmium in printing inks for the application of enamels on borosilicate glass. [21]

4 Cadmium plating means any deposit or coating of cadmium on a metallic surface.

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A3ii. Reportable Substances (“Reportable” if intend to use)

The following substances (Table B1) have been shown to have the potential to cause adverse health effects or have the potential to generate hazardous waste. Consequently, these substances may be subject to legislative control in certain market areas. If a “reportable” material is considered for use in equipment, spare parts, or accessories, it must be reported to Xerox using form EHS-1001B. Additional requirements apply to Xerox consumables as defined in Xerox EH&S Standard 701 for Materials.

Table B1. Xerox Reportable Substances

Antimony and its compounds Arsenic and its compounds Beryllium and its compounds Bismuth and its compounds Bis-phenol A (BPA) Indium Nickel and its compounds Phthalate (DINP) Phthalate (DIDP) Phthalate (DNOP) Tris (2-chloroethyl) phosphate (TCEP) (CAS# 115-96-8) Engineered nanomaterials – specify type PVC (PVC in packaging is prohibited) Selenium and its compounds

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The following substances (Table C1) have been identified as “substances of very high concern” and as such are subject to specific requirements under the EU REACH Regulation 1907/2006. Use of these substances in Xerox parts, accessories or consumables is to be reported to Xerox using form EHS1001C. In some instances, individual substances are already prohibited from use in products or parts supplied to Xerox, as outlined in Tables A1 and A2. Important Note

The number of substances of very high concern will increase in time as the European Chemicals Agency adds substances of very high concern to its candidate list. Table C1 below is current as of December 2009 and will be updated periodically but it is essential that suppliers inform themselves of the latest position, since this is updated by the European Chemicals Agency every six months. Information on the latest list of substances of very high concern is available through the European Chemicals Agency website at: http://echa.europe.eu/. When completing Xerox EHS-1001 Form C, “Supplier Use of REACH Substances”, Xerox is relying on its suppliers to be aware of the latest candidate list and to report accordingly.

Table C1. REACH Reportable Substances

Substance CAS # Anthracene 120-12-7 4,4'- Diaminodiphenylmethane 101-77-9 Dibutyl phthalate 84-74-2 Cobalt dichloride 7646-79-9 Diarsenic pentaoxide 1303-28-2 Diarsenic trioxide 1327-53-3 Sodium dichromate 7789-12-0, 10588-01-9 5-tert-butyl-2,4,6-trinitro-m-xylene (musk 81-15-2 xylene Bis (2-ethyl(hexyl)phthalate) (DEHP) 117-81-7 Hexabromocyclododecane (HBCDD) and all 25637-99-4 and 3194- major diastereoisomers identified (α – HBCDD, 55-6 β-HBCDD, γ-HBCDD) (134237-51-7, 134237- 50-6, 134237-52-8) Alkanes, C10-13, chloro (Short Chain 85535-84-8 Chlorinated Paraffins) Bis(tributyltin)oxide 56-35-9 Lead hydrogen arsenate 7784-40-9 Benzyl butyl phthalate 85-68-7 Triethyl arsenate 15606-95-8

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Appendix B

Xerox Environment, Health and Safety Policy Xerox Corporation is committed to the protection of the environment and the health and safety of its employees, customers and neighbors. This commitment is applied worldwide. The following principles shall govern all business practices in the design, manufacture, procurement, marketing, distribution, maintenance, reuse/recycling and disposal of products and related services:

1. Protection of the environment and the health and safety of our employees, customers and neighbors from unacceptable risks takes priority over economic considerations and will not be compromised. 2. Xerox operations must be conducted in a manner that safeguards health, protects the environment, conserves valuable materials and resources, and minimizes risk of asset losses. 3. Xerox is committed to designing, manufacturing, distributing and marketing products and processes to optimize resource utilization, prevent pollution and minimize environmental impacts. 4. All Xerox operations and products are, at a minimum, committed to compliance with applicable governmental requirements and Xerox standards. 5. Xerox is dedicated to continuous improvement of its performance in environment, health and safety.

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Appendix D

Revision History

Date Section Change October 2004, VI.A.4 Consumables removed from scope of standard revision 2.1 October 2004, Appendix B2 Table B3 changed to “reportable substances” and list reduced to relevant metals and revision 2.1 compounds in hazardous waste legislation (all organic compounds removed, bismuth added) March 2005, Table B2. ROHS Updated table with exemptions approved by EU Technical Advisory Committee on revision 2.2 Exemptions December 10, 2005 March 2005, Appendix C Revision to form EHS 1001A, B and C to clarify their intent and use revision 2.2 March 2005, Table 1, This table was split into Table 1A to reflect RoHS requirements only and Table 1B for revision 2.2 Prohibited other prohibited substances. This change was made to avoid confusion. The Substances requirements remain the same. March 2005, Footnote, A.3.i Revised to include the EU’s definition of “homogenous substance”. revision 2.2 March 2005, Table 3 Nickel, Tin and Zinc compounds reinstated for hazardous waste purposes. revision 2.2 November 2005, Table 1-A Table and footnote revised for consistency with Decision 2005/618/EC and Commission revision 2.3 guidance dated May 2005. November 2005, Table 2 Table revised to align the numbering system with that in the Annex to Directive revision 2.3 2002/95/EC, to include new listings from Commission guidance dated May 2005, and to adopt new exemptions in Decisions 2005/717/EC and 2005/747/EC. Footnote revised. November 2005, Table B3 Table revised to include radioactive substances, and flame retardants other than PBBs revision 2.3 and PBDEs. January 2006, Table 1-B Table revised to be consistent with Joint Industry Guide. revision 3.0 January 2006, Table B3 Table revised to be consistent with Joint Industry Guide. revision 3.0 December 2006, Table 2 Table revised to adopt new exemptions in Decisions 2006/310/EC, 2006/690/EC, revision 3.1 2006/691/EC and 2006/692/EC. August 2007 1.3 Added EMS responsibility.

2.5 Added packaging requirements.

A.2 Added definition of batteries.

Table 1-B Table revised to include ban on use of cadmium in portable batteries in Directive 2006/66/EC, and updated to harmonized list. Added prohibition of halogen–containing plastics as packaging.

Table revised to remove exemption [28] on chromium passivisation, which became obsolete on 1 July 2007. Table 2

Tables 1A, 1B, 2, 3 Table 1A - Specification that deca-BDE is prohibited was added under Polybrominated June 6, 2008 and Forms EHS- diphenylether (PBDEs) 1001A and EHS- Table 1B - Hexachlorobenzene and Perfluorooctane Sulfonates were added 1001B Table 1B - Requirements for batteries was added under Cadmium, Lead and Mercury Table 1B - References were added

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Table 2 RoHS Exemptions - Exemption 9a for decaBDE in polymeric applications was removed Table B3 Reportable Substances - Added the following: Bisphenol-A, Indium, DEHP Table B3 Reportable Substances - Polybrominated Flame retardants now includes HBCDD and TBBPA Table B3 Reportable Substances - Added specification that use of PVC in packaging is prohibited Table B3 Reportable Substances - Changed “Nickel compound - not including the metallic element” to Nickel and its compounds Form EHS-1001A - Replaced column A.3.ii for reporting weight of component batteries, and removed exemption 9a Form EHS-1001B - Added columns for Bisphenol-A, Indium, DEHP Form EHS-1001B - Changed text in Polybrominated Flame retardants to include HBCDD and TBBPA December 1, 2008 Table 1B Table 1B – Replaced 91/157/EEC with 2006/66/EC Table B3 Table 1B – Specified marking requirement for batteries containing lead Tables 1B and 1C – Added specification for formaldehyde emissions Table 1D – Added table of inorganic cyanide compounds Table B3 – Replaced Diethylhexyl phthalates (DEHP) with Phthalates (including DEHP, BBP, DBP) March 31, 2009 Table 1B Appendix A.2 – added a definition for engineered nanomaterials Table B3 Table A1 – Added references to Blue Angel Table B4 and Table A2 – Added Phenol,2-(2H-benzotriazol-2-yl)-4,6-bis (1,1-dimethylethyl), removed EHS1001C PBDO. Table B1 – Deleted HBCDD, DEHP, BBP and DBP as these are now included in Table C1. Risk assessment data has resulted in the delisting of TBBPA. Added DINP, DIDP, DNOP, TCEP and engineered nanomaterials. Table C1 – Added REACH substances of very high concern and associated EHS-1001C reporting form. Editorial changes to table numbering scheme

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